FAQs

In this edition, we offer the following questions and answers regarding disclosing Financial Interests and Outside Activities with a foreign entity in response to the new question 12 in the AA-21.

These FAQs provide general guidelines for all employees. For more specific guidance, please contact: PCA@ucf.edu

Should I continue engaging in international partnerships and activities?

Yes! International partnerships and international activities are a key and valuable part of academia.  Question 12 was added to the AA-21 to assist UCF personnel in meeting certain federal and state reporting requirements and allows UCF to evaluate whether there is a potential inappropriate foreign influence risk that requires additional review by UCF.

Am I required to track the physical location of my co-authors or have them notify me anytime they leave the U.S.?

No. Under question 12 in the AA-21, disclosers are expected to disclose Outside Activities with a foreign entity or individuals who they generally know reside outside of the U.S. However, disclosers are not required to track the physical location of their co-authors or have their co-authors notify them anytime they leave the U.S.

Are there certain financial interests or activities with foreign entities that do not need to be disclosed to UCF?

Yes. The Outside Activity, Financial Interest and Potential Conflict Disclosure Matrix identifies several financial interests and activities with foreign entities that do not need to be disclosed under question 12 in the AA-21.  If the activity is identified as a reporting exclusion, then the discloser can respond “no” to the applicable part(s) of question 12 and not report the activity.

Under question 12 in the AA-21, how much detail do I need to disclose in the description of the activity?

UCF does not expect disclosers to provide a technical description of any research or technology.  However, the discloser should provide enough information on the who, what, when, and where related to the Outside Activity to allow a reasonable person to understand the context of the activity.  Providing this information upfront will decrease the likelihood of any follow up questions.

I am engaging in research with an external collaborator that is physically located outside of the U.S. and is affiliated with a foreign entity.  Do I need to report the name of the individual or the name of the entity in “Entity Name” under question 12 in the AA-21?

If the Outside Activity is with the external collaborator in their role at the foreign entity, then the discloser should report the name of the foreign entity and identify the individual in the description of the activity.  If the Outside Activity is just with the external collaborator (i.e. the foreign entity is not involved in the collaboration), then the discloser should report the name of the external collaborator.

I am engaging in unfunded research with a foreign entity.  Do I need to report this research to UCF?

It depends.  If the unfunded research qualifies as an Outside Activity, then yes, this research must be reported.  However, if the research is funded through UCF or there is a contractual relationship with the foreign entity through UCF, then the activity does not qualify as an Outside Activity and would not need to be reported (See the Outside Activity, Financial Interest and Potential Conflict Disclosure Matrix).

If I am working with an international publishing company to publish a book/journal article do I need to disclose this as an outside activity to UCF in response to question 12 in the AA-21?

No. The Outside Activity, Financial Interest and Potential Conflict Disclosure Matrix specifically identifies book reviews, editing books/journal articles, and working with an international publishing company to publish a book/journal article as reporting exclusions.  If an activity is identified as a reporting exclusion, then the discloser can respond “no” to the applicable part(s) of question 12 and not report the activity.

If my financial interests or outside activity is identified as a reporting exclusion, do I still need to report it on my AA-21?

No. If an activity is identified as a reporting exclusion, then the discloser can respond “no” to the applicable part(s) of question 12 and not report the activity.

If the activity is funded by UCF, do I still need to disclose the activity on my AA-21?

No. An activity funded by UCF would not qualify as an Outside Activity.

Am I required to know whether my external collaborators have foreign funding?

No. Under question 12, disclosers are expected to disclose Outside Activities with a foreign entity or individuals who they generally know reside outside of the U.S. Disclosers are not required to investigate the funding of their external collaborators.

“Discussions with potential collaborators” is identified as a reporting exclusion on the Outside Activity, Financial Interest and Potential Conflict Disclosure Matrix.  How are discussions with potential collaborators different than engaging in research?

Discussions with potential collaborators are different than engaging in research because a decision hasn’t been made to collaborate or engage in research activities (i.e. these are preliminary discussions).  Once an agreement (verbal or written) is made to engage in research activities the UCF individual should determine whether the activity qualifies as an Outside Activity, and if so, report the Outside Activity at that time.

Peer-review of articles already requires the disclosure of essential information about co-authors on publications.  Why do I need to report this information on my AA-21?

While Peer-review may require reporting essential information about authors, the purpose of the UCF conflicts of interest and commitment disclosure process is to assist UCF personnel in identifying conflicts of interests/commitments and assist with mitigating any conflicts of interests/commitments earlier in the process (i.e. when an agreement is made to engage in an Outside Activity, not when the Outside Activity has already been completed).

Research is conducted with external collaborators and the employee has research as part of their UCF FTE.  Does this require reporting as an Outside Activity or is this activity part of the employee’s assigned duties at the university?

It depends.  Just because research is identified as part of a UCF’s employees FTE does not mean that the individual is exempt from reporting any research activities.  If the research qualifies as an Outside Activity, then the research must be reported.  However, if the research is funded through UCF or there is a contractual relationship with the foreign entity through UCF, then the activity does not qualify as an Outside Activity and would not need to be reported (See the Outside Activity, Financial Interest and Potential Conflict Disclosure Matrix).

Research that qualifies as an Outside Activity is conducted with external collaborators who do not reside in the U.S.  Does the employee need to report each of the collaborator’s names in question 12 as separate entities for the same study?

It depends.  If the external collaborators are conducting the research as part of the same foreign entity, then the discloser should report the name of the foreign entity and identify the individuals in the description of the activity.  If there is a combination of multiple foreign entities and external collaborators who do not reside in the U.S., then each foreign entity/collaborator should be reported separately.  With that said, rather than re-inserting the same information that has already been entered for the study, it is absolutely acceptable to say, “see above” in the “description of the activity.”